VKXET
SECTION
‘*’ &.\Vt~l
BEFORE THE
POSTAL RATE COMMlSSlON
WASHINGTON, D.C. 20268-0001
POSTAL RATE AND FEE CHANGES, 1997
Docket No. R97-1
i
RESPONSE OF UNITED STATES POSTAL SERVICE
WITNESS NEEDHAM TO INTERROGATORIES
OF
DAVID B. POPKIN
REDIRECTED FROM THE POSTAL SERVICE
(DBP/USPS-21, 37, 54, AND 62)
The United States Postal Service hereby provides responses o,f witness
Needham to the following interrogatories
and 62, filed on September
of David B. Popkin:
DBPIUSPS-21,
10, 1997, and redirected from the Postal Service.
motion for extension of time to file these responses was filed on September
An objection to DBPIUSPS-21
A
29, 1997
(parts m-p, r, v. y-aa, and cc) was filmedon September
25, 1997, and an objection to DBPIUSPS-54
September
37, 54,
(parts bb, and kk-tt) was filed on
29, 1997
Each interrogatory
is stated verbatim and is followed by the resiponse
Respectfully submitted,
UNITED STATES POSTAL SERVICE
By its attorneys:
Daniel J. Foucheaux, Jr.
Chief Counsel, Ratemak,ing
% f-2J2wu.,
David H. Rubin
475 L’Enfant Plaza West, S.W.
Washington, D.C. 20260-1137
(202) 268-2986; Fax -5402
October 2, 1997
RESPONSE OF WITNESS NEEDHAM TO
INTERROGATORIES
OF DAVID B. POPKIN
(REDIRECTED FROM THE UNITED STATES POSTAL SERVICE)
DBPIUSPS-21. With respect to Special Handling, (a) provide copies of all
directives and instructions which indicate how this mail is to be handled and
processed. (b) Are there any delivery service standards for Special Handling
mail as opposed to Priority Mail and Standard Mail which have their standards
shown in the chart accompanying the response to Rule 54(n)? (c) If so, what are
they? (d) Assume for purposes of the following that I mail nine packages in the
Englewood, NJ post office on Monday, July 14, 1997. Three packages are
destined to New ‘York, NY, another three to Marked Tree, AR, and the last three
to Los Angeles, CA. For each of the destinations, one package is sent Standard
Mail (B), the second is sent Standard Mail (B) - Special Handling, :and the third is
sent Priority Mail. Describe the handling of each of the nine packages including
the facilities that they will transit through and the expected time at each of the
facilities and the delivery time of each. If handling would be different for different
weights, explain and provide information for each of the different weight groups.
(e) Other than those instances where Special Handling must be used because of
the nature of the contents of the parcel, what advantages may one expect by
utilizing Special Handling with a Standard Mail (B) parcel? (f) Explain how and
why one would u,tilize Special Handling with First-Class Mail as noted in DMCS
Section 952.21 (a). (g) DMCS Section 952.2 indicates that Special Handling is
mandatory for certain mail matter. Is DMM Section S930.2.4 the only reference
to the type of mail which must be sent Special Handling? (h) If nol:, provide any
other type of mail and the appropriate reference. (i) May parcels crontaining
honeybees or baby poultry or any other mail matter provided in your response to
subpart h be mailed by Priority Mail without requiring the additional Special
Handling fee? fj) If not, explain why not and provide the appropriate reference.
(k) Disregarding the cost of mailing, are there any circumstances or conditions
where a knowledgeable mailer would utilize Standard Mail (B) - Special Handling
for a particular parcel rather than utilizrng Priority Mail? (I) If so. explarn and list
the reasons. (m) Confirm, or explain if you are unable to do so, th,at the
maximum proposed cost for a Priority Mail parcel weighing ten pounds or less
will be $14.85 and that the fee for Special Handling for parcels weighing ten
pounds or less will be $17.25. (n) Confirm, or explain if you are unable to do so,
that a Priority Mail parcel weighing ten pounds or less will always [cost less than
the Special Handling parcel of the same characteristics and destination. (0)
Confirm, or explain if you are unable to do so, that the fee for Special Handling
for parcels over ten pounds will be $24.00. (p) Confirm, or explairr if you are
unable to do so, that when the Special Handling fee is added to the Inter-BMC
Standard Mail rates that Prrority Mail will be less expensive than the Standard
RESPONSE OF WITNESS NEEDHAM TO
INTERROGATORIES
OF DAVID B. POPKIN
(REDIRECTED FROM THE UNITED STATES POSTAL SERVICE)
DBPIUSPS-21.
Continued
Mail rate for all but the following cells: Zones 1 and 2, over 63 pounds; Zone 3,
none; Zone 4, over 48 pounds; Zone 5, over 49 pounds, Zone 6, over 44
pounds; Zone,7, over 46 pounds; and Zone 8, over 44 pounds. (q) What
percentage of all Inter-BMC parcels fall into the cells noted in subpart p? (r)
Confirm, or explain if you are unable to do so, that when the Special Handling
fee is added to the Intra-BMC Standard Mail rates that Priority Mail will be less
expensive than the Standard Mail rate for all but the following cells: Local, over
60 pounds; Zones 1 and 2, over 61 pounds; Zone 3, over 67 pounds; Zone 4,
over 43 pounds; and Zone 5, over 46 pounds. (s) What percentage of all IntraBMC parcels fall into the cells noted in subpart r? (t) May Special Handling be
utilized with the various destination Standard Mail rates? (u) If so, confirm that
because mailers who utilize the destination rates by transporting the parcel to
the destination facility have already eliminated the practical reasons for utilizing
Special Handling for other than those instances where it would be mandated for
parcels containing honeybees or baby poultry (v) If you are unable to confirm
subpart u, provide those categories and weight cells where Special Handling
would be less expensive than Priority Mail. (w) What percentage Iof all
destination rate parcels would fall into the cells noted in subpart v. (x) What
percentage of all parcels falling into the categories and cells specified in subpart
v would be expected to utilize Special Handling? (y) Confirm, or explain if you
are unable to do so, that the maximum weight for Bound Printed Matter will be 15
pounds and that the maximum postage for a 15 pound Priority Mail parcel will be
$21.05. (z) Confirm, or explain if you are unable to do so, that a Priority Mail
parcel will always cost less than a Bound Printed Matter parcel sent by Special
Handling. (aa) Confirm, or explain if you are unable to do so, that when the
Special Handling fee is added to the Special Standard Mail rates that Priority
Mail WIII be less expensive than the Standard Mail rate for all but the following
cells: Zones Local, 1, 2, and 3, none; Zone 4, over 49 pounds; Zone 5, over 44
pounds; Zone 6, over 34 pounds; Zone 7, over 30 pounds; and Zclne 8, over 23
pounds. (bb) What percentage of all Special Standard Mail parcels falls into the
cells noted in subpart r? (cc) Confirm, or explain if you are unable to do so, that
when the Special Handling fee is added to the Library rates that Priority Mail will
be less expensive than the Standard Marl rate for all but the following cells:
Zones Local, 1, :2, and 3, none; Zone 4, over 53 pounds; Zone 5, rover 47
pounds; Zone 6, over 36 pounds, Zone 7, over 32 pounds; and Zone 8, over 25
RESPONSEOFWITNESSNEEDHAMTO
INTERROGATORIES OF DAVID B POPKIN
(REDIRECTED FROM THE UNITED STATES POSTAL SEIRVICE)
DBPIUSPS-21,
Continued
pounds. (dd) What percentage of all Library parcels fall into the cells noted in
subpart r? (ee) What percentage of all standard mail parcels fall into the rate
cells noted in response to subparts p, r, v, aa, and cc? (ff) Based on the above,
will it be expected to have many parcels sent Special Handling by
knowledgeable mailers? (gg) Is it the intention of the Postal Service to price
Special Handling in a manner so that it will follow in the footsteps of Special
Delivery and be discontinued in the next rate case or shortly thereafter? (hh) If
not, explarn. (ii) On page 6 of the 1997 booklet “Get More From Your Post
Office” it indicates that, “Special handling mail travels in distinctive sacks and
containers to set it apart from other mail.” List the types of sacks and containers
that are used. (ii) Confirm, or explain if you are unable to do so, that these sacks
and containers are only used for Special Handling mail.
RESPONSE.
a) See Postal Operations Manual 7 (August 1, 1996) at 137.453 and Domestic
Mail Manual Issue 52 (July 1, 1997) S930.1 .O.
b) Special handling delivery standards are the same as those for the type of
Standard Mail used. Due to the nature of those items shipped with special
handling, postal employees may telephone recipients of special handling
pieces to notify them that they can pick up their special handling mail if they
do not wish t’o wait for later delivery by the letter carrier
c) See response to DBP/USPS-21
(b)
RESPONSE OF WITNESS NEEDHAM TO
INTERROGATORIES
OF DAVID B. POPKIN
(REDIRECTED FROM THE UNITED STATES POSTAL SERVICE)
DBPIUSPS-21.
Continued
d) There is not enough information to answer your interrogatory
accurately.
For
example, are the Standard Mail (B) parcels machineable or nonmachineable?
In any case, much of the information you request would
require a special study.
e) One may expect preferential
purchasing
f)
handling in dispatch and transponation
when
special handling service.
One would pay the special handling fee in addition to First-Class Mail
postage to receive preferential handling in dispatch and transportation.
g) DMM 52 Sect/on S930.2.4 does not refer to special handling.
h) See DMM 52, Sections S930.1 .l and S930.1.4.
i) Yes.
j)
Not applicable.
k) I am not aware of any research on this subject, however I presume there are
knowledgeable
mailers who would value the preferential
and transportation
that special handling sewice provides over Priority Mail.
I) See the response to DPBIUSPS-21
(k).
m) Objection filed.
n) Objection filed.
---
handling in dispatch
--~
RESPONSE OF WITNESS NEEDHAM TO
INTERROGATORIES
OF DAVID B. POPKIN
(REDIRECTED FROM THE UNITED STATES POSTAL SERVICE)
DBPIUSPS-21.
Continued
o) Objection filed.
p) Objection filed.
q) See the parcel post billing determinants
in USPS LR H-145.
r) Objection filed.
s) See response to DBP/USPS-21 (q).
t)
Special handling is available for use with Standard Mail (A) single piece and
all of the Standard Mail (B) subclasses.
u) Not confirmed.
v) Objection filed.
w) See response to DBPIUSPS-21 (q).
x) See the special handling billing determinants
y) Objection filed.
z) Objection filed.
aa) Objection filed.
bb) See response to DBPIUSPS-21 (q).
cc) Objection filed.
in USPS LR H-145.
RESPONSE OF WITNESS NEEDHAM TO
INTERROGATORIES
OF DAVID B POPKIN
(REDIRECTED FROM THE UNITED STATES POSTAL SERVICE)
DBP/USPS-21.
Continued
dd) See response to DBP/USPS-21 (q).
ee) See response to DBPIUSPS-21 (q).
ff) Please see USPS-T-39 Workpaper
13 for the after rates special handling
volumes.
cm) No.
hh) It is the intention of the Postal Service to price special handling to cover its
costs and meet the other applicable statutory criteria of the Postal
Reorganization
Act. See USPS-T-39, pages 84 to 86, for an e:rplanation of
the proposed special handling fee development.
ii) The types of sacks and containers used would vary by individual post office
jj) I cannot confirm because as stated in my response to DBP/USPS2l(ii),
sacks and containers used would vary by office, and could theoretically
sacks and containers alternatively used by another type of mail.
any
be
RESPONSE OF WITNESS NEEDHAM TO
INTERROGATORIES
OF DAVID B. POPKIN
(REDIRECTED FROM THE UNITED STATES POSTAL SE,RVlCE)
DBPIUSPS-37
[a] Confirm, or explain if you are unable to do so, that prior to
Docket MC96-3 a mailer desiring Registered Mail service for an article with a
declared value of up to $25,000 could mail the article both with or without postal
Insurance. [b] Confirm, or explain if you are unable to do so, that as a result of
Docket MC96-3, the maximum value for making the choice of purchasing postal
insurance or not was reduced to $100. [c] Confirm, or explain if you are unable
to do so, that in this Docket, it is proposed to reduce that amount to $0, namely,
for an article having a declared value of one cent or more, it is required to
purchase postal insurance [I understand that the maximum insurance liability is
limited to $25,000].
[d] In the preparation for Docket MC963 was it the
intention of dropping the limit from $25,000 to $100 only because the Postal
Service wanted to eliminate non-postal insurance in two steps rather than doing
it all at once? [e] Confirm, or explain if you are unable to do so, that with
respect to the Registered Mail service that there are some costs which are
independent of the value of the article, there are some costs ,which are only
slightly related to the value of the article, and those costs which are directly
related to the declared value. [fj Confirm, or explain If you are unable to do so
as well as provide any other additional items, that the following costs are the
same regardless of the declared value of the article: preparation, storage, and
utilization of forms; training of employees, publicity of the service, acceptance of
the article, and processing [not the payment ofJ any inquiries and claims. [g]
Confirm, or explain if you are unable to do so as well as provide any other
additional items, that the following costs are only slightly related to the declared
value of the artimcle: security and transportation of the article from the time it is
accepted until it is delivered to the addressee. [h] Confirm, or explain if you are
unable to do so as well as provide any other additional items, that the following
costs are directly related to the declared value of the article: payment of any
claims for damage or loss. [i] Provide the cost per anrcle for all of the items that
are listed in response to subpart f. [j] Provide the cost per article for all of the
items that are listed in response to subpart g. This should be sh’own for each of
the 27 or 28 rat’e categories. [k] Provide the cost per article for all of the items
that are listed in response to subpart h. This should be shown for each of the 27
or 28 rate categories.
[I] Provide a table over a period of a recent IZ-month
period showing the number of articles mailed in each of the 27 Irate categories,
the number of claims that were filed in each of the 27 rate categories, and the
average value paid out per claim in each of the 27 categories. \:m] Confirm, or
explain if you are unable to do so, the requirement, and provide the appropriate
reference, that a mailer must declare the full value of an article for which
registration is desired, in] Confirm, or explain if you are unable to do so, that
RESPONSE OF WITNESS NEEDHAM TO
INTERROGATORIES
OF DAVID B. POPKIN
(REDIRECTED FROM THE UNITED STATES POSTAL SERVICE)
DBPIUSPS-37
Continued
the marler will communicate the declared value to the acceptanlce clerk at the
time of mailrng the arbcle. [o] Confirm, or explain if you are unable to do so, that
for any other postal employee to know the declared value of an article, that
information must be specrfically communicated to them from the original
acceptance clerk. [p] Confirm, or explain if you are unable to do so, that if this
communication chain between any two postal employees is broken, it will not be
possible to accurately determine the declared value of the article. (q] Confirm,
or explain and provide specific information if you are unable to do so, that no
record of the declared value is transmitted as a matter of course as the article
moves through the mail system. [r] Confirm, or explain if you are unable to do
so, that it is not possible to accurately determine the declared valiue of an article
by just looking at the article. Note: This may be due to the overpayment of
postage or part or all of the postage falling off. [s] Confirm, or explain if you are
unable to do so, that the likelihood of any given postal employee looking at a
registered mail article, determining the postage paid on the article, and
calculating the registry fee by weighing the article and subtracting the postage
for that weight along with the fees for any other services, such as Return Receipt
or restricted delivery and then converting that registry fee just to determine the
declared value will be extremely small. [t] Confirm, or explain if you are unable
to do so, that for articles with a declared value of $25,000 or less that it will be
unlikely that the value of the article will be specifically communicated from
employee to employee. [u] If you are unable to confirm subpart I:, are there any
regulations or directives indicating a specific value for which the communication
of the declared value of the article must be communicated between employees.
If so, specify the value, provide copies of the directive or regulation, and
enumerate the ‘way the communication will take place. [v] If there are no
regulations or directives in your response to subpart t, provide the values at
which you believe 25%, 50%, 75% and 100% of the employees will resort to
communicating the declared value as the article moves through the system and
the method that will be utilized to pass such information.
[w] In light of your
responses to subparts n through v, explain how it is possible to justify any higher
costs for the transportation and security of articles with a declared value of
$25,000 or less and provide a breakdown between the costs for each of the 27
or 28 different value steps, [x] Confirm, or explain if you’are unable to do so,
that Registered Mail may only be utilized for First-Class Mail. [y] Confirm, or
explain if you are unable to do so, that First-Class Mail is sealed agatnst postal
RESPONSE OF WITNESS NEEDHAM TO
INTERROGATORIES
OF DAVID B. POPKIN
(REDIRECTED FROM THE UNITED STATES POSTAL SERVICE)
DBPIUSPS-37
Continued
inspection. [z] If a mailer does not file a claim for loss or damage, how will it be
possible for the Postal Service to know the contents or actual value of an article
which is registered?
[aa] If a mailer does not file a claim for loss or damage,
what sanctrons can be applied to the mailer for failing to declare the full value?
[bb] How will it be possible for the Postal Service to determine the existence of
such a condition? [cc] Isn’t such a rule unenforceable with respect to articles for
which the mailer is not interested in obtaining postal insurance
[dd] If not,
explain. [eel Because of the inability to enforce this rule, doesn’t it fall into the
same category as the Postal Service’s change of the rule with respect to Return
Receipt for Merchandise where the use of First-Class Mail under 11 ounces was
no longer authorized as of Docket MC96-3 because of the inability of the Postal
Service to determine that the article actually contained merchanclise. [ffl If not,
explain. [gg] Confirm, or explain if you are unable to do so, that there are
customers who, for whatever reason they may have, do not want to purchase
postal insurance for their registered articles. [hh] Confirm, or explain if you are
unable to do so, that some of the reasons a mailer might not want to purchase
postal insurance would be, they already have their own insurance, they are only
interested in obtaining the secure handling that registered mail provides, or the
cost vs. value ratio was low enough to assume the risk. [ii] Provide any other
reasons in addition to those in subpart hh. b] What is the logic for requiring a
mailer to purchase a service that do not want or need? [kk] Is postal insurance
primary or secondary to any other insurance that a mailer may have? [II] If it is
secondary, then explain why a mailer should be required to purchase it. [mm]
Confirm, or explain if you are unable to do so, that the only article for which no
postal insurance is required is one which has a value of $0.00 [as opposed to
one which has a value of $0.01 for which postal insurance must be purchased].
[nn] If a registered article is completely lost, may the claim include not only the
value of the contents but any or all of the following: the value of the container or
envelope that the contents were in, the postage paid for mailing the article [not
including any fees], the registration fee, the postage paid for any other specral
services such as Return Receipt or restricted delivery? Indicate which, if any, of
the items are covered and provide a copy of the regulation supporting your
responses. [oo] If any of the items
RESPONSE OF WITNESS NEEDHAM TO
INTERROGATORIES
OF DAVID B. POPKIN
(REDIRECTED FROM THE UNITED STATES POSTAL SERVICE)
DBPIUSPS-37
Continued
specified in subpart nn are covered, wouldn’t that automatically provide a value,
albeit only perhaps a penny, which would preclude declaring a value of $0.00.
[pp] If not, explain. [qq] Refer to POM Section 811.22 and confirm, or explain If
you are unable to do so, that if I purchase stock at a cost of $1,000 and at the
time of mailing it has a market value of $5,000, and if I mail the stock certificate
endorsed in blank, I must pay for a declared value of $5,000. [rr] Same as
subpart qq, except that if I purchase jewelry for $1,000 and it now has a market
value of $5,000, I would be permitted to pay for a declared value of only $1,000~
[ss] If you confirm both subparts qq and rr, explain why the two articles are
treated differently. [tt] Refer to POM Section 811.22 and confirm, or explain if
you are unable to do so, that if I mail a negotiable instrument, susch as a bearer
bond, I must declare a value which is the replacement value of thalt article, which
just happens to be its market value. [uu] Same as subpart tt, except that if I mail
a nonnegotiable instrument, I am given the option of whether or not I want to
declare a value equal to its replacement cost or to declare no value even if there
is a replacement cost. [vv] If you confirm both subparts tt and uu, explain why
the two articles are treated differently. [ww] Refer to POM Section 811.22 and
confirm, or explain if you are unable to do so, that any of the articles listed under
nonnegotiable instruments or nonvaluables will, in fact, have at Ileast a minimal
intrinsic value, albeit perhaps only a penny for the intrinsic value for a sheet of
paper. [xx] If you are able to confirm subpart ww explain why these categories
are treated differently than those under other categories which it is required to
declare the market value or cost. [yy] Are there any articles whic:h are normally
being registered that have an intrinsic value of $0.00 as opposed to $0.01 or
more? [u] If so, specify examples. [aaa] Refer to POM Section 811.24 and
explain where the authority comes from to inquire about the contents of FirstClass Mail.
RESPONSE:
a) Confirmed
RESPONSE OF WITNESS NEEDHAM TO
INTERROGATORIES
OF DAVID B. POPKIN
(REDIRECTED FROM THE UNITED STATES POSTAL SE.RVICE)
DBP/USPS-37
Continued
b) Confirmed th,at the maximum level for uninsured registered mail was
decreased from $25,000 to $100 as a result of Docket No. MC’36-3.
c) Confirmed th,at the proposal in this docket is to reduce the maximum level for
uninsured registered mail from $100 to $0 00.
d) In the preparation
of Docket No. MC96-3 the Postal Service only considered
proposing the reduction of the maximum value level for uninsured registered
mail from $25,000 to $100, and did not consider any further decrease.
e) Not confirmed.
There are costs both independent of the declared value and
related to the declared value, but not necessary only slightly rctlated to the
declared value.
f)
Not confirmed.
Registered items with very high declared values could
require additional training of employees, particularly for those items requiring
special circumstances
g) Not confirmed.
frequently
to handle.
Registered items with extremely high declared values
require added security and alternative transportation,
which are directly related to the declared value.
h) Confirmed, to the best of my knowledge
the costs of
RESPONSE OF WITNESS NEEDHAM TO
INTERROGATORIES
OF DAVID B. POPKIN
(REDIRECTED FROM THE UNITED STATES POSTAL SERVICE)
DBPIUSPS-37.
Continued
I) This information
j)
is not available in the breakdown you request.
See response to DBPIUSPS-37(i).
k) See response to DBP/USPS37(i).
I) See the registered mail billing determinants
in USPS LR H-145; for the
number of registered articles mailed in each of the 27 fee categories for
1997. Claims information will be provided later.
m) See DMM S911.2.1 and my response to DBPIUSPS-38(e).
n) Confirmed.
o) Not confirmed.
A registered mail article’s declared value can tie determined
by postal employees through calculating the postage and subtracting
it and
any ancillary service fees from the total amount paid to get the registered
mail fee. Even if an exact calculation is not made, a general estimate of the
item’s value can be made from the total postage and fees.
p) Not confirmed.
See the response to DBP/USPS-37(o).
q) Confirmed
r) Not confirmed.
In the majority of situations, postage has not falllen
postage has been neither underpaid nor overpaid.
Consequently,
off
or
it would be
RESPONSE OF WITNESS NEEDHAM TO
INTERROGATORIES
OF DAVID B. POPKIN
(REDIRECTED FROM THE UNITED STATES POSTAL SERVICE)
DBPIUSPS-37.
Continued
r) Continued
very possrble to accurately determine the declared value of an article by
looking at the article.
s) Not confirmed.
No data exists on the number of times postal employees
would calculate or estimate the declared value of a registered article based
on the affixed postage and fees.
t)
Not confirmed.
Postal employees are required to do what is necessary for
the safe and secure transport of all registered mail; communicating
declared value of articlesunder
the
$25,000 can be one way of ensuring this
safety and security.
u) I know of no regulations or directives, but I am aware that there may be
certain circumstances
in which communicating
the declared vsllue of articles
under $25,000 may be necessary for safety and security and that this would
be done on an individual basis
See response to DBP/USPS37(t).
RESPONSE OF WITNESS NEEDHAM TO
INTERROGATORIES
OF DAVID B. POPKIN
(REDIRECTED FROM THE UNITED STATES POSTAL SERVICE)
DBPIUSPS-37.
Continued)
v) Since communication
of the declared value would be done on an individual
basis depending upon the circumstances,
as to the percentage
I could not begin to hazard a guess
of the total number of registered mailings It would be
done.
w) The higher the declared value of registered articles, the higher the costs for
security and accountability.
The requested breakdown of costs is not
available.
x) Confirmed that registered mall may only be used for articles paying FirstClass Mail rates.
y) Confirmed.
z) The Postal Service relies upon the declared value given by the mailer to
determine the amount of security during the dispatch, processing, and
delivery functions of the registered mailpiece.
aa)-dd)
It generally would not be possible.
I am unaware of any aittempt to
impose penalties on mailers in the circumstances
you describe.
The primary
reasons for a mailer to declare full value are to enable the Postal Service to
provide the proper level of security, and to protect himself or herself should
the registered item be lost or damaged.
To some extent, however, the Postal
Service relies on the integrity of its custome<to declare full value when
RESPONSE OF WITNESS NEEDHAM TO
INTERROGATORIES
OF DAVID B. POPKIN
(REDIRECTED FROM THE UNITED STATES POSTAL SERVICE)
DBPIUSPS-37.
Continued
uu)Yes.
vv) The issuer of a negotiable instrument probably would be reluci:ant to proffer a
replacement,
cashed.
with the original remaining in circulation and subject to being
Conversely,
the issuer of a nonnegotiable
instrument has no
apparent risk in providing a replacement at minimal cost.
ww) Please refer to my responses to partzoo) and pp) above.
xx) See vw
yy) Regulations
require that a customer must truthfully declare only the full or
actual value. An item’s intrinsic value would come into play only in
adjudication.
zz) See the response to DBPIUSPS-37(yy).
aaa) It is my understanding
that the fact that mail is sealed against inspection
does not preclude asking the mailer about the contents.
RESPONSE OF WITNESS NEEDHAM TO
INTERROGATORIES
OF DAVID B. POPKIN
(REDIRECTED FROM THE UNITED STATES POSTAL SERVICE)
DBP/USPS-37.
aa)-dd)
ee)-ff)
Continued
requested to do so.
No. See my testimony, USPS-T-8, in Docket No. MC96-3 for the reasons
for the return receipt for merchandise classification
gg)Confirmed
change.
that some customers have chosen not to purchase insured
registered mail.
hh) Not confirmed.
The Postal Service does not have information as to why
some registered mail customers would choose not to use postal insurance
ii) Not applicable.
jj) There is no logic in providing a service that is not frequently used, as was
demonstrated
in the Docket No. MC96-3 Recommended
Decision which
eliminated the service offerings and fee categories for uninsured registered
mail from $100.01 to S25,OOO. Further, with respect to this doc,ket, see my
testimony at pages
kk) Primary
II) Not applicable~
n-78.
RESPONSE OF WITNESS NEEDHAM TO
INTERROGATORIES
OF DAVID B. POPKIN
(REDIRECTED FROM THE UNITED STATES POSTAL SERVICE)
DBP/USPS-37.
Continued
mm) Not confirmed.
A customer may choose uninsured registered marl up to
$100 in declared value.
nn) If a special or custom-made
container were used (such as for shipping birds,
etc ), the Postal Service would consider its cost in processing ;s claim. We
do not refuncl the registration fee itself. We do automatically
in a claims payment.
include postage
Other fees are refunded as deemed appropriate.
For
example, if the customer actually received his return receipt, we would not
refund that fee. If he did not receive his return receipt, we wotlld make such
a refund.
oo)-pp)
No. The declared value is not the same as the actual or .fair-market
value used for determining claims, and declaring value does not
automatically
give an item actual value
94 Yes.
rr) Yes.
ss) Unlike stock, a wholesaler would place one value on jewelry (wholesale
cost), while his customer.would
place a higher value (retail price).
tt) No. Market value still applies~ The replacement cost is not necessarily
market value of the bond
the
RESPONSE OF WITNESS NEEDHAM TO
INTERROGATORIES
OF DAVID B. POPKIN
(REDIRECTED FROM THE UNITED STATES POSTAL SERVICE)
DBPIUSPS-54
[a] A rate is being proposed 500 banded stamped envelopes
which costs 50 cents to $1.00 more than the rate for 500 plain stamped
envelopes.
What are banded stamped envelopes?
[b] What value does a
purchaser of banded stamped envelopes obtain for their added 50 cents to
$1.00 cost? [c] What is the added cost for the Postal Service to provide 500
banded stamped envelopes over 500 plain stamped envelopes? [d] Confirm, or
explain if you are unable to do so, that plain hologram stamped envelopes will
only be available in single sales. [e] Confirm, or explain if you are unable to do
so, that printed hologram stamped envelopes will not be available in the 6-3/4
size. [fj Confirm, or explain if you are unable to do so, that fclr 500 stamped
envelopes of the 6-3/4 size, the difference between the plain and printed
versions is $14.00 less $8.50 or a difference of $5.50 which represents the cost
of printing. [g] Confirm, or explain if you are unable to do so, that for 500
stamped envelopes of greater than the 6-3/4 size, the difference between the
plain and printed versions is $15.00 less $11.50 or a difference of $3.50 which
represents the cost of printing. [h] Provide the cost data for printing both the 63/4 size as well as the larger than 6-3/4 size envelopes.
[i] E:xplain why the
printing cost for the 6-3/4 size stamped envelopes is 57 percent more than the
printing cost of the larger envelope. k] Confirm, or explain if you are unable to
do so, that the item in Fee Schedule 961, “Multi-Color Printing (500) ” refers to
price for those plain [as opposed to printed] stamped envelopes which are
printed in two or more colors or whrch are precancelled for the regular or nonprofit Standard Mail rates. [k] Confirm, or explain if you are unable to do so,
that the stamped envelopes which meet the criteria specified in subpart j may not
be purchased with a printed return address. [I] Confirm, or explain if you are
unable to do so, that for 500 stamped envelopes of the 6-314 size, the difference
between the plain one-color and plain multi-color versions is $1400 less $8.50
or a difference of $5.50 which represents the cost of the added icolor printing of
the stamp design. [m] Confirm, or explain if you are unable to do so, that for
500 stamped envelopes of greater than the 6-3/4 size, the difference between
the plain one color and plain multi-color versions is $15.00 less $11.50 or a
difference of $3.50 which represents the cost of the added color printing of the
stamp design, [n] Provide the cost data for printing the multi-color designs, both
the 6-3/4 size as well as the larger than 6-3/4 size envelopes. [o] Explain why
the printing cost for the 6-3/4 size stamped envelopes is 57 percent more than
the printing cost of the larger envelope since the stamp design is the same for
both envelopes.
[p] Confirm, or explain if you are unable to do so, that the
current 32 cent stamped envelope which was issued for regular use [as opposed
to a commemorative, limited issue] is printed in two colors [q] For each of the
RESPONSE OF WITNESS NEEDHAM TO
INTERROGATORIES
OF DAVID B. POPKIN
(REDIRECTED FROM THE UNITED STATES POSTAL SERVICE)
DBPIUSPS-54
Continued
regular issue, First-Class Mail rate stamped envelopes that have been issued
since 1971, provide a listing of the face value of the stamp, the description of the
design, and the number of colors utilized in the printing. [r] Provide a similar
listing for all precancelled stamped envelopes. [s] Provide a simrlar listing for all
other stamped envelopes, such as commemorative and special issues. [t] If the
proposed rate is implemented, WIII all post offices stock single color stamped
envelopes for sale to the public? [u] If not, explain why the public will be forced
to buy the multi-color version at the higher price. [v] What is the justification for
charging the higher multi-color rate for precancelled envelopes automatically
even if they should be printed in one color only? [w] Confirm, or explain if you
are unable to do so, that savings bond stamped envelopes will only be available
In the printed version and will not be available in the plain version. [x] Confirm,
or explain if you are unable to do so, that the household (50) rates relate to
printed stamped envelopes. [y] Confirm, or explain if you are unable to do so,
that the added cost for a hologram stamped envelope as compared to a nonhologram stamped envelope will be one cent for a single sale, one-half cent for
the household fifty purchase [$3.50 vs. $3.25 for 50 envelopes], and eight-tenths
of a cent for the 500 printed envelopes [$19,00 vs. $15.00]. [.z] Why is the
added per envelope charge for fifty envelopes less than for 500 envelopes? [aa]
Will the stamped envelope design which utilizes a multi-colored picture pasted
on the inside of the envelope and showing through a square/rectangular
cutout
in the envelope, as has been utilized on a number of previous issues, be
categorized as a multi-color version or as a hologram version? [bb] Confirm, or
explain if you are unable to do so, that the single sale price of seven cents will
apply to all plain stamped envelope sales of less than five hundred envelopes,
including sales of precancelled envelopes for philatelic purposes, regardless of
the type or design [other than those that have an actual hologram as part of the
design for which the price will be eight cents]. [cc] Confirm, or explain if you are
unable to do so, that the selling price for a single stamped envelope will be
seven or eight cents per envelope when sold in lots of 1 to 499 stamped
envelopes and will be only 1.7 cents to 2.3 cents when sold in a lot of 500
envelopes
[dd]
What are the added costs that accrue when stamped
envelopes are sold in lots of 1 to 499 envelopes? [eel Are there any costs other
than the apparent extra window sales time? [q If so, enumerate and quantify
the cost. [gg] Confirm, or explain if you are unable to do so, that the cost for 32
RESPONSEOFWITNESSNEEDHAMTO
INTERROGATORIES
OF DAVID B. POPKIN
(REDIRECTED FROM THE UNITED STATES POSTAL SERVICE)
DBPIUSPS-54
Continued
cent stamps is 32 cents each, whether a mailer purchases one stamp or a million
stamps or any number in between.
[hh] Explain the logic and justification
behrnd selling single stamped envelopes at a price which is greater than the
multiple price when the same is not justified for the sale of stamps. [ii] Is one
reason, that 18 USC 1721 will permit it for stamped enveloples but not for
stamps? h] Confirm, or explain if you are unable to do so, that a mailer desiring
between 501 and 999 stamped envelopes would pay a fee of $8.50 or $11.50 for
the first 500 envelopes and seven or eight cents for each of the envelopes
above 500. [kk] Confirm, or explain if you are unable to do so, that printed
stamped envelopes are available from one source only and that there is a
charge by that single source over and above that which appears in the Fee
Schedule. [II] What is that single source for printed stamped envelopes? [mm]
What is the added charge requrred in ordering printed stamped envelopes? [nn]
What is the justification for charging this added fee when it does not appear in
the Fee Schedule and has not been approved by the Postal Rate Commission?
[oo] Will an added fee be required under the proposed rates? [pp] If so,
quantify and explain. [qq] Are there any other services for which the United
States Postal Service is proposing in this Docket which will not be available at
the rate shown in the various rate and fee schedules? [rr] If so, quantify and
explain. [ss] Are refunds available for those that have paid this added fee which
was not approved by the Postal Rate Commission. [tt] If not, explain why not.
[uu] Confirm, or explain if you are unable to do so, that if this docket is approved
the price of a single First-Class Mail stamped envelope will go from 38 cents to
40 cents. [vv] Confirm, or explain if you are unable to do so, that the rate
increase for both the First-Class Mail postage and the stamped envelope will go
into effect at the same time. [w-w] Confirm, or explain if you are unable to do so,
that it has been the practice of the Postal Sen/ice to release tlie new valued
stamped envelope prior to the effective date of the rate increase. [xx] Confirm,
or explain if you are unable to do so, that if this policy is continued that the
selling price for ,a 33 cent stamped envelope purchased between the issue date
of it ?nd the effective date of the new rates would be 39 cents [33 cents postage
plus the 6 cent stamped envelope fee in effect at that time]. [yy] Confirm, Or
explain if you are unable to do so, that in a similar manner, the sale of stamped
cards would be 21 cents during the period of time between the issue date and
the effectrve date of the proposed 2 cent fee, [u] Will post offices be advised of
the requirement of subparts xx and yy so that the proper rate may be charged?
[aaa] If not, why not? [bbb] One of the rates being proposed is for a fee of
RESPONSE OF WITNESS NEEDHAM TO
INTERROGATORIES
OF DAVID B. POPKIN
(REDIRECTED FROM THE UNITED STATES POSTAL SERVICE)
DBP/USPS-54
Continued
2 cents for a stamped card. Was any consideration given to having a bulk rate
for them similar to the one in place and being proposed for stamped envelopes?
[ccc] If so, why wasn’t it implemented? [ddd] If not, why not?
RESPONSE:
a) Banded stamped envelopes are stamped envelopes sold in pa’cks of five with
a band around them. Banded stamped envelopes can come in 6 % and 10
inch sizes and are always regular (not window) plain stamped Ienvelopes.
b) The question is not entirely clear. Are you referring to the “cos,~” as exhibited
in USPS LR H-l 07, page 55 or the proposed fees in USPS-T-39 WP-15?
The cost for 500 6 % inch banded stamped envelopes in USPS LR H-l 07 is
$10.27, while the cost for 500 6 % inch aggregated stamped envelopes is
$6.97, for a difference of $1.30. The cost for 500 10 inch banded stamped
envelopes in USPS LR H-107 is $12.26, while the cost for 500 10 inch
aggregated
stamped envelopes is $11.41, for a difference of $0.85. The
proposed fee for 500 6 % inch banded stamped envelopes is 9#9.50, $1.30
higher than the current fee, yet $0.77 lower than the cost. The proposed fee
for 500 10 inch banded stamped envelopes is $12 00, $1 .OO loswer than the
RESPONSE OF WITNESS NEEDHAM TO
INTERROGATORIES
OF DAVID B. POPKIN
(REDIRECTED FROM THE UNITED STATES POSTAL SEIRVICE)
DBPIUSPS-54
Continued
b) Continued
current fee, and $0.26 lower than the cost
For the higher fees customers
get stamped envelopes which are banded into packs, and which cost more to
produce
c) See the response to DBP/USPS-54
d) Not confirmed.
e) Confirmed.
(b).
See USPS-T-39, page 96, lines 4-13.
Hologram stamped envelopes have only been available in the 10
inch size since they were issued.
f)
Confirmed only that the proposed fees for 6 % inch stamped envelopes are
$5.50 higher than the plain for the printed envelopes.
Not confirmed that this
$5.50 difference represents the printing cost.
g) Confirmed only that the proposed fees for 10 inch stamped envelopes are
$3.50 higher than the plain for the printed envelopes.
Not conlfirmed that this
$3.50 difference represents the printing cost.
h) See USPS LR H-l 07. pages 45-50.
i)
See my testimony at page 95, lines 6-21, and page 96, lines 1-13, for a
discussion of the development
of the stamped envelope fees.
RESPONSE OF WITNESS NEEDHAM TO
INTERROGATORIES
OF DAVID B. POPKIN
(REDIRECTED FROM THE UNITED STATES POSTAL SERVICE)
DBPIUSPS-54
j)
Continued
Not confirmed. Multi-color prrnting refers to the envelope you d’escribe in part
aa~
k) Not confirmed.
Printing is available for all stamped envelopes.
I) Confirmed.
m) Confirmed.
n) See USPS LR H-107, pages 45-50.
o) See response to DBPIUSPS-54(i).
p) Confirmed that the Liberty Bell is green and the “USA 32” is blue. However,
these envelopes are not considered ‘multi-color’ for purposes of the multicolor fee. See my response to j.
q) See attached list for all stamped envelopes available from the :Stamped
Envelope Agency since 1965.
r) See the response to DBPIUSPS-54(q).
s) See the response to DBPIUSPS-54(q).
t) All post offices that offer stamped envelopes will offer at least one type not
subject to multi-color fee.
u) Not applicable.
RESPONSE OF WITNESS NEEDHAM TO
INTERROGATORIES
OF DAVID B. POPKIN
(REDIRECTED FROM THE UNITED STATES POSTAL SERVICE)
DBPIUSPS-54
Continued
v) Customers are not charged the multi-color fee for precancelled
w) Not confirmed.
envelopes.
Savings bond stamped envelopes have been discontinued.
x) Confirmed that the household stamped envelope fees are for printed
stamped envelopes.
y) Confirmed only that the proposed fee of a single hologram is one-cent more
than the proposed fee for a srngle non-hologram
stamped envelope, the
proposed fee for household hologram envelopes is $0.25 than the proposed
fee for non-hologram
household envelopes, and the proposed fee for
hologram 500 box lots is $4.00 higher than the proposed fee for the nonhologram 500 box lots.
z) See response to DBP/USPS-54(i).
aa)
Multi-color.
The space station stamped envelope is the only hologram
stamped envelope currently offered.
bb) Confirmed with respect to non-philatelic
sales of stamped envelopes.
cc) Confirmed, although if a customer wished to purchase 999 stamped
envelopes, for example, two box lots of 500 would be the wise choice, as
opposed to one box of 500 and 499 single sale envelopes.
RESPONSE OF WITNESS NEEDHAM TO
INTERROGATORIES
OF DAVID B. POPKIN
(REDIRECTED FROM THE UNITED STATES POSTAL SERVICE)
DBP/USPS-54
dd)
Continued
See USPS LR H-107, pp 47-48, for the single sale costs versus the box lot
costs.
ee)
No.
ff)
Not Applicable.
gg)
Confirmed, assuming by ‘cost’ you mean ‘rate’.
hh)
In both cases the price of postage is the same regardless of the quantity
purchased.
Stamped envelopes, unlike stamps have a special service fee,
which does vary based on the quantity purchased.
ii)
No.
i)
See response to DBPIUSPS-54(cc).
kk-tt) Objection filed September 29, 1997.
uu)
Confirmed only for the total price of non-hologram
stamped envelopes.
vv)
To the best of my knowledge all rates and fees would be implemented
the same time.
ww) Not confirmed.
Post offices may receive one of each type of advance
stamped envelope with the new postage rate prior to the implementation
date, for display purposes.
at
RESPONSE OF WITNESS NEEDHAM TO
INTERROGATORIES
OF DAVID B. POPKIN
(REDIRECTED FROM THE UNITED STATES POSTAL SERVICE)
DBP/USPS-54
Continued
xx) There is no such policy.
yy) Not confirmed.
Post offices may receive one of each type of advance
stamped card with the new postage rate prior to the implementation
date, for
display purposes.
zz) Not applicable.
aaa) Not applicable.
bbb) No.
ccc) Not applicable.
ddd) The Postal Service first needs to see if a fee for stamped cards will be
approved before deciding whether bulk fees are appropriate.
a/21/71
-
19 Symbolic
Milwaukee
WI
Bird in Flight ‘Airmail’
The American
Farmer ~_
Commemorative
_~
11 l-61 t
123-643
141~641
’
E/6/76
10/15/76
Ilancock
MA
1.0s Anycla~
CA
..-...
NAME
NUMBERS
161-162~661-662
31 Goll Commemorative
32 Octagon ‘Auth Non-Profit’
33 Energy Conservation
lSpsclal
~-t-
DATE
1
1 DENOM.
- -~~~
LOCATION
Houslon
13
2,l~
13
TX
Issue1 Comm
’
512278
Memphis
’
7128178
g/2/76
Wllllamsburg
Onlsno CA
36 Uncle Sam
37 ‘Aulh Non~Prnfil’
ReCtanQle
~._~
~~-..-~~
36 16 Cent USA Revalued
4OtLiberty Tree 13 Cent Revalued
41 “Au;h-Non~Prafil’
Rectangle w/rounded
13
Al151
I5
2.7~
15
TN
PA
corners
44i%v@5omn~~mvtive
12/10/79
5/16/80
Easl Rutherford
Baltimore MD
lO/lO/BO
3/15/81
~4/2/Etl
6/13/81
Paris IL
Memphis TN
Star City IN
Arlington WA
11/13/61
Los Angeles
NJ
I5
15
3.1
15
15
.r
PMS NUMRFR -
1
Yellow.tlLack.R~dil64)
Yellow,Black,Red11841
Brown
IBlue 13001
GraY(404).Black,Browr~~1541
IRed.Blach.Greenl361)
%/Violin
’ Aufh Non-Profit’
46 America’s Cup Comr%moralive
48 Eagle ‘B’
49 New Slar
50 Blinded Veteran
.51/Eagle ‘C’
52 ICapitol Dome
53 ‘Auih Non-Profil’
Commemorative
__~~~~
-.
64 Precancellad Bison
{Sub 20 Unwateryked
for Reader’s
Digesll
161-162-661-662
171-172.671-612
124.624
131-132-631~632
/lOl-102-601-602
,
‘i
i
I
10131/86
133
~~--__~
~~-.~ .~.~~~~
-~-:-m/i6
146-147~646-647
65 Mayll&er
‘Auth Non-Profit’
~.__
66 Treasury Bond (Official Mail Stamp)
~~115fPln)116~Prldl
(Sub 20 Unwatermarked
Not embossed1
12117~2118
6, I’E’ Savings Bond (not embossed)
‘2161-2162-2661-2662;
66 l~hineen Slar
HH
-2151-2152-2661~2652:
!Tt,,rteen Slar
500
: 3/21/87
3/2%/68
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16
16
Cf20)
CA
‘~
(No Ceremony)
P&&h
MA
Washington
Washin9ton
DC
DC
Starti;-~~~~-~~~~~
~slue 1301)
;Red (200). Blue 1301)
lBrown (4711
20
;Purple 1215)
5.9
;l3rown 14701
20 ~---d-~-L IBlue1293lRed12001EIsck
Purple (266) Black
20
20~Gj9y1
‘Orange (151)
5.2
Red[lB5~Blue1267~Black
20
Blue12E6)Purplef2651Redl186)
20
Green (3341
D(22)
Brown (5041
2 2:22
Blue
__-...-~(2931
Aqua 1320)
6
22
a.5
Brown
(5041
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Process Black
22
El251
:I’::
25
Blue 1293)
Blue, Black
Blue. Red
-.-~
-
I
I691Penalty Mail (Official Mail)
~~
I .~~~~ smbossedlplal”
70.Saw”gs
Bond (not
lop flap
71 Constellarlo”
‘Aulh Non-Profit’
72 , Thirteen
Double
Window
Plain
~~--_~~ Srar~~~~.
~~---~~
~.73lHollday
Snowflake
74:Savings
Bo”d(“Ti
embossedlprtd
top flap
-75;lnaugural
Envelapell3StarlSat
ol 6
;
Poslmarked
with 1st Day Cities: Greenwich
76 13 Star Phllatelic _~~-~__~~
Cor”memorallVe~.
69
-i7 DOEI 13 Star Envelooe
ITEM
NUMBERS
12110-2117
210B~Plnl~2I09~Pfidl
,Washinglon
;Washmglon
DC
DC
25
25
25
L
Iii >olis IN Kennebunkport
ME
3/l 0/89CCle”ela”dOH
.P!n)-2165lPrtdl
6/14/89
ItNo Cetemonyl
2154 HH2155
Reg
7/10/99
‘Washington
DC
~~~~ ~.-------..2---~
2168 HH2169
I 9/22/99
‘McLean VA-.
25
- I MA
~~ z
Love
500
96 Single Srar Security
#9
Grav 182!51. Blue
Red
I1 651, Grean
Black
Red
TX
j6::i,;;:l
Rsdiii&-
25
25
25
‘Blue. Red
‘Blue. Red
Blutl. Red
;;~
p;
3/l 7/90
7/4/90
:2174
HH2172
‘2106
(Pl”l2107lPrtdl
Washington
Washinglon
DC
DC
I
::
65
45
65
25
29
1 91 IPenalty Mail IOllicial Mall)
! g&DOD Single
~.___~Star (Regular1 __~~
93’Savings
Bond (not embossed)
94 Birds On A Wire ‘Auth Non-Prolit’
.~ .~.~.
95 Lgyp
HH
Dark
Blue,
Red
Blue,
Blue.
Houston
oil-line)
2144
2145
2140
Trophy)
4/l 1 /BE
4/12/68
(one-time manufacturing
of 3,OOO.OOO envelopes
produced
81 ,A2 Security #9 lspeclal window)
~R?ISnace Stnrinn Holooram #9
12156 HH2157
B4.Passoorl
ESPassport
_~~~
i 86 Passoort Peal & Seal
~ 671Passport Peal & Seal
tlB/Football
Hologram ILombardi
C”L”H/
NUMBER
LOCATION
121 16lPlnl 21 lS(Pridl
2146-2147-2646-264
2179-2699
-12178-2668-
F129l
~~29
29
29
11.1
Honolulu
HI
29
:@&Ill~
maim-:-::
j:::-%&Black
;Biie(29Zil
Black
lElue (293) Black
IBlue
I2931 Black
Hologram
-
Palch
Blue (293) Red (185)
Blue 1293) Black 19991
Blue (2931 Black 19941
Blue (2931 fled 11851
Blue (293) Black 19991
Blue/3001 Red f 1661
CarmineRose[2131Purplef2591
Env Aqualope Blue
HH
,Single Star Securily #9
500
97,Arirona
Security (Special window envelope1
96 DOD Smgle Star (Window1
99 Magazine Industry
100 Country Geese 166.3/4)
101 Counlry Geese I#101
102 Space Stgltun holoyram
103 Wcstcrn Americana
l&l :?rratect the E~rv~ror~marr~llI~llal~randia 1lo~wcr~HII
‘2192
HH2193
~2176
HH2177
(2123.HlH2124
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HHZlEE
i.
7/20/g 1
E/l 6/9 1
9/30/g 1
1 O/6/9 I
I 1 /B/9 1 ]Vriyinla Beach VA
‘Vriyinia Beach VA
l/21/92
Virginia Baach VA
1121192
Dodye City KS
4/10/92
‘Clllca~,o IL
4/22/92
29
29
29
29
29
29
29
29
29
:Bluel26B~Red
I1 B6)
‘Blue (2861 Red (1861
Blue 1293) Red I1 851
BlackYellowBlueRedGree”
Bluc(549)Vellow(l221
Blue(549)Yellowl1221
Green (369~denoml
Lallermy(redd#sh
BllPalch
YellnwM~~e~,laCyanClelac
c
:k
ITEM
NUMBEAS
..~ j--.-,
DATE
2143
2144
~
2145
2194.2679
~~-iAmerlcans
with Disabdities
. 500
2191-2678
1% K%ten2195
HH2196
~~-~~___-~-.-~~~~
2166
HH2169
I 10 Football lembossedl
~~~~~~ __-~ ~~~~ 2121-2122-2623-2624
I1 1 ‘G’ Old Glory
..____~
2101-2102-2625-2629
11-i Libeny Bell
HH
L!beny Bell
500
~~___
.~~ 2154-2155-2637-2638
~~~~~
~~~~~ ~- ~~~
~-~
53 OOD Liberty ~~~__~~~~~~
Beli
2161 fPln) 2162 (Prtd)
~~~~
I 14 Graphic Eagle
Bulk Rate
~~~__
~~~~.lNondenominaledl
-~ --___~
~~~~~ 12153
‘2151~2152-2627-2628
115 ISheep ‘Auth Non-Profit’
INandenominaled)
LOCATION
;
5/17/92 ~~ ~I‘Las
~~~ Vegas NV
7/10/92
IWashinglon
DC
-~--I~
~~~-~~~
7/10/92
Washington
DC
7/22/92
10/l 193
g/17/94
12/13/94
Washington
DC
King of Prussia PA
Canton OH
Washington
DC
l/3/95
2/16/95
3/10/95
3/10/95
Wilhamsburg
PA
INo Ceremony)
State College PA
Stale College PA
Washingron
DC
19.6
52
Ji
~ed(ltl618lue(286I
I:d(032)Blue
(072)
ted(032)Blue(072)
29
29
29
llus Red
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RESPONSE OF WITNESS NEEDHAM TO
INTERROGATORIES OF DAVID B. POPKIN
(REDIRECTED FROM THE UNITED STATES POSTAL SERVICE)
DBPIUSPS62
Provide a listing for each of the following services indicate (sic),
I, the rate being proposed; 2. the cost for providing the service for the proposed
rate, 3. the cost coverage percentage for the proposed rate, 4. the present rate,
5. the cost of providing the service for the present rate, and 6. the cost coverage
percentage related to the existing rate: [a] Fee Group C - PO Box size 1, [b]
size 2, [c] size 3, [d] size 4, [e] srze 5, [t-j Fee Group C -Caller Service, [g]
Certified Mail [also provide data for pre-MC96-3 rate], [h] Return Receipt, [i]
Return Receipt for Merchandise, [i] Return Receipt issued after mailing, [k]
individual Certificate of Mailing, [I] Special Handling, [m] Single Stamped
Envelope, [n] Single Hologram Stamped Envelope, [o] Plain box of 500
stamped 6-3/4 size envelopes, [p] size 10 envelope, [q] process’ing and
handling a stamped card, [r] processing and handling a post carcl, and [s] fee
for the stamped card itself.
RESPONSE:
In all but parts g, I, and s, I am providing information related to impllicit cost
coverages,
rather than a cost coverage, which applies to an entire special
service or subclass of mail.
a) 1) See USPS-T-39,
page 59,
2) See response to DFCIUSPS-T39-1
3) See response to DBPIUSPS-62(a)(2)
4) See response to DBP/USPSS2(a)(l)
5) See response to DBPIUSPS62(a)(2)
6) See response to DBP/USPS62(a)(2)
b) 1) See response to DBP/USPS62(a)(l)
-.-
RESPONSE OF WITNESS NEEDHAM TO
INTERROGATORIES OF DAVID B. POPKIN
(REDIRECTED FROM THE UNITED STATES POSTAL SERVICE)
DBPIUSPS-62
Continued
b) Continued
2) See response to DBP/USPS62(a)(2).
3) See response to DBP/USPS-62(a)(2).
4) See response to DBP/USPS62(a)(l).
5) See response to DBP/USPS62(a)(2).
6) See response to DBP/USPS62(a)(2).
c) 1) See response to DBP/USPS62(a)(l).
2) See response to DBP/USPSZ2(a)(2)
3) See response to DBP/USPS62(a)(2),
4) See response to DBP/USPS62(a)(l).
5) See response to DBP/USPS62(a)(2).
6) See response to DBP/USPSZ2(a)(2).
d) 1) See response to DBP/USPS62(a)(l)
2) See response to DBP/USPS62(a)(2).
3) See response to DBP/USPS62(a)(2).
4) See response to DBPIUSPS-62(a)(l).
5) See response to DBPIUSPS-62(a)(2).
6) See response to DBP/USP%62(a)(2).
RESPONSEOFWITNESSNEEDHAMTO
INTERROGATORIES
OF DAVID By POPKIN
(REDIRECTED FROM THE UNITED STATES POSTAL SERVICE)
DBPIUSPS-62
Continued
e) 1) See response to DBPIUSPS62(a)(l).
2) See response to DBPIUSPS-62(a)(2),
3) See response to DBP/USPS62(a)(2).
4) See response to DBP/USPS62(a)(l)
5) See response to DBP/USPS62(a)(2).
6) See response to DBP/USPS62(a)(2).
f)
1) See USPS-T-39,
page 59.
2) See LR H.-l 07, page 11.
3) 181 percent
4) See response to DBP/USPS62(f)(l).
5) Assumrng the same cost from USPS LR H-107, the current cost would be
$304.50 per year.
6) Assuming the same cost from USPS LR H-107, the current cost coverage
would be 148 percent
g) For the pre-MC96-3 fee, see Docket No. MC96-3, USPS-T-e, p. 58
1) See USPS-T-39,
page 26, Table 5.
RESPONSE OF WITNESS NEEDHAM TO
INTERROGATORIES
OF DAVID B. POPKIN
(REDIRECTED FROM THE UNITED STATES POSTAL SEIRVICE)
DBPIUSPS-62
Continued
g) Continued
2) See USPS-T-39 WP-17 (revised August 22, 1997) page 1, column 3.
3) See USPS-T-39 WP-17 (revised August 22, 1997), page I, column 5.
4) See response to DBP/USPS62(g)(l).
5) For the Test Year Before Rates the cost is 338,734,OOO
6) For the Test Year Before Rates the cost coverage is 121 percent.
h-k) Answered by witness Plunkett.
I
1) See USPS-T-39,
page 81, Table 14.
2) See USPS-T-39,
WP-17, page 4, column 3.
3) See USPS-T-39, WP-17, page 4, column 5.
4) See response to DBP/USPS-62(1)(1).
5) For the Test Year Before Rates the cost is 1,272,OOO.
6) For the Test Year Before Rates the cost coverage is 34.7 percent.
m) 1) See USPS-T-39,
page 92, Table 16.
2) See USPS LR H-l 07, page 55.
3) See response to DFCIUSPS-T39-19.
4) See response to DBP/USPS62(m)(l).
RESPONSE OF WITNESS NEEDHAM TO
INTERROGATORIES
OF DAVID B. POPKIN
(REDIRECTED FROM THE UNITED STATES POSTAL SEIRVICE)
DBPktSPS-62
Continued
m) Continued
5) Assuming the same cost in USPS LR H-107, see response i,o DBP/USPS62b-W).
6) Assuming the same cost in USPS LR H-107, see response I:o DBPIUSPS62(m)(3).
n) 1) See response to DBP/USPS62(m)(l).
2) See response to DBP/USPS62(m)(2).
3) See response to DBP/USPS62(m)(3).
4) See response to DBP/USPS62(m)(l).
5) Assuming the same cost in USPS LR H-107, see response tic DBPIUSPS62(m)(2).
6) Assuming the same cost in USPS LR H-107, see response to DBPIUSPS62(m)(3).
o) 1) See response to DBPIUSPS-62(m)(l).
2) See response to DBPIUSPS-62(m)(2).
3) 95 percent
RESPONSE OF WITNESS NEEDHAM TO
INTERROGATORIES
OF DAVID B. POPKIN
(REDIRECTED FROM THE UNITED STATES POSTAL SERVICE)
DBPktSPS-62
Continued
o) Continued
4) See response to DBP/USPS62(m)(l).
5) Assuming the same cost as presented in USPS LR H-107, see USPS LR
H-l 07, page 55
6) Assuming the same cost as presented in USPS LR H-107, gl percent.
p) The answers to these subparts were answered going under the assumption
that you were referring to a plain box of 500 regular stamped 110inch size
envelopes:
1) See response to DBP/USPS62(m)(l).
2) See response to DBP/USPS62(m)(2).
3) 101 percent
4) See response to DBP/USPS62(m)(l).
5) See response to DPB/USPS62(o)(S)
6) Assuming the same cost as presented in USPS LR H-l 07, 105 percent.
q) 1) See USPS-T-32.
2) See Exhibits USPS-30A8B.
3) See response to DBPIUSPS-62(q)(2).
RESPONSE OF WITNESS NEEDHAM TO
INTERROGATORIES
OF DAVID 8. POPKIN
(REDIRECTED FROM THE UNITED STATES POSTAL SERVICE)
DBPIUSPS-62
Continued
q) Continued
4) See response to DBPIUSPS62(q)(l).
5) See response to DBP/USPS-62(q)(2).
6) See response to DBPIUSPS62(q)(2).
r) 1) See response to DBP/USPS62(q)(l).
2) See response to DBP/USPS62(q)(2).
3) See response to DBP/USPS-62(q)(2).
4) See response to DBP/USPS62(q)(l).
5) See response to DBP/USPS62(q)(2).
6) See response to DBP/USPS62(q)(2).
s) 1) See USPS-T-39,
page 87, Table 15.
2) See USPS-T-39, WP-17, page 4, column 3.
3) See USPS-T-39, WP-17, page 4, column 5.
4) See response to DBP/USPS62(s)(l).
5) Assuming the same cost as presented In USPS LR H-107, see response
to DBPIUSPS-62(s)(2).
6) Not applicable, since there is presently no fee revenue.
DECLARATION
I, Susan W. Needham. declare under penalty of perjury that the foregoing answers
are true and correct, to the best of my knowledge, information. and belief.
CERTIFICATE
OF SERVICE
I hereby certify that I have this day served the foregoing document upon all
participants
of record in this proceeding in accordance with section 12 of the Rules of
Practice.
53iaJ-knLL
David H. Rubin
475 L’Enfant Plaza West, S.W.
Washington, D.C 20260-I 137
October 2. 1997